ACIT, CIRCLE-3(1),, VIJAYAWADA vs. SRI BHASKAR CONTRACTORS COMPANY,, VIJAYAWADA

In the result, appeals of the revenue for the A

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकरअपीलसं./I.T.A.No.109/Viz/2013 (निर्धारणवर्ा/Assessment Year : 2008-09) Asst.Commissioner Of Vs. M/S Sri Bhaskar Contractors Income Tax Company Circle-3(1) D.No.60-3-27, F.No.101 Vijayawada Sai Aniketh Apartment Iti Bus Stop, Ashok Nagar Vijayawada [Pan : Aaqfs5687P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) Cross Objection No.70/Viz/2013 (Arising Out Of I.T.A. No.109/Viz/2013) M/S Sri Bhaskar Contractors Asst.Commissioner Of Company Income Tax D.No.60-3-27, F.No.101 Circle-1(1) Sai Aniketh Apartment Vijayawada Iti Bus Stop, Ashok Nagar Vijayawada [Pan : Aaqfs5687P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 40A(3) and wrongly grouped the sum of Rs.1,50,00,000/- under chips instead of labour charges in letter dated 29.12.2010. Pucca vouchers could not be produced for labour, loading and unloading of earth work, chips etc. Only kachha vouchers for chips were maintained. The assessee further stated in respect of 40A(3) submissions that the assessee

THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,,ELURU vs. THE ACIT,, VISAKHAPATNAM

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

THE ITO, WARD-2, ELURU, ELURU vs. M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD., ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,ELURU vs. THE ITO, WARD-2, ELURU, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

THE ACIT,, ELURU vs. M/S. THE DISTRICT CO - OPERATIVE CENTRAL BANK LTD., ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

THE ACIT., CIRCLE - 1, ELURU, ELURU vs. M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,,ELURU vs. THE ACIT,, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,ELURU vs. THE ITO, WARD-2, ELURU, ELURU

In the result, the appeals filed by the assessee in ITA No

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

sections specified there or otherwise. The Board thus has power, inter al/a, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under s. 119 which are binding on the authorities in the administration of the Act. Under s. 119(2)(a), however, the circulars

THE KANAKAMAHALAKSHMI CO-OPERATIVE BANK LIMITED,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

3. After hearing both the parties, we are of the opinion that similar issue came up for consideration in assessee's own case for assessment year 2002-03 in I.T.A. No. 349/Hyd/2006. The Tribunal decided the issue in favour of the assessee vide its order dated :15.2.2008 by holding as follows: "4. We have considered rival submissions on either side

THE KANAKAMAHALAKSHMI CO-OPERATIVE BANK LIMITED,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

3. After hearing both the parties, we are of the opinion that similar issue came up for consideration in assessee's own case for assessment year 2002-03 in I.T.A. No. 349/Hyd/2006. The Tribunal decided the issue in favour of the assessee vide its order dated :15.2.2008 by holding as follows: "4. We have considered rival submissions on either side

RANAR AGROCHEM LIMITED,PARAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, VISAKHAPATNAM

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

depreciation of Rs.6,63,63,807/-against the addition under Sec.68 r.w.s. 115BBE(2) of the Act may be allowed in the interest of equity the assessed income of Rs.3,47,97,000/- which also included and justice and also to be in conformity with enacted law and also judge made law. 6. In the facts and circumstances

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

40A(7) of the Act. The Ld. AO observed that while passing the order U/s. 143(3) this was not disallowed which is a mistake 61 apparent from record and therefore issued a notice U/s. 154 of the Act. In response, the assessee submitted that to match with the actuarial liability of gratuity fund of Rs. 133.03 Crs, an addition